- 1 - HC-KAR NC: 2025:KHC:35264 WP No. 19528 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 28TH DAY OF AUGUST, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 19528 OF 2024 (T-IT) BETWEEN: 1. M/S ANODE BUSINESS SOLUTIONS G-35, KGA GARDEN, C BLOCK, 1A PEENYA INDUSTRIAL AREA, 2ND PHASE, BENGALURU -560 058 (REPRESENTED BY ITS PARTNER MS. KAVITHA RANI) …PETITIONER (BY SRI. SACHIN S NAYAK, ADVOCATE) AND: 1. THE INCOME TAX OFFICER WARD 1(2)(1), BENGALURU THE ASSESSING OFFICER UNDER THE INCOME TAX ACT, 1961 BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095. 2. PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU-1, THE SPECIFIED AUTHORITY U/S 151 OF THE INCOME TAX ACT, 1961 BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU -560 095. 3. NATIONAL FACELESS ASSESSMENT CENTRE, NOW KNOWN AS NATIONAL E-ASSESSMENT CENTRE REP. BY PRINCIPAL CHIEF COMMISSIONER Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:35264 WP No. 19528 of 2024 OF INCOME TAX (NEAC), ROOM NO.401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, NEW DELHI - 110 003. 4. CENTRAL BOARD OF DIRECT TAXES REPRESENTED BY IT'S CHAIRMAN DEPARTMENT OF REVENUE, NORTH BLOCK, NEW DELHI-110 001. …RESPONDENTS (BY SRI Y V RAVI RAJ AND SRI M DILIP, ADVOCATES) THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE NOTICE UNDER CLAUSE (B) OF SECTION 148A OF THE INCOME TAX ACT, 1961 DATED 23/01/2023 FOR THE A.Y. 2019-20 ISSUED BY THE RESPONDENT NO. 1 BEARING DIN VIZ ITBA/AST/F/148A(SCN)/2022-23/1049016984(1) WHICH IS ENCLOSED AS ANNEXURE A AND QUASHING OF THE ORDER UNDER CLAUSE (D) OF SECTION 148A OF THE INCOME TAX ACT, 1961 DATED 27/03/2023 FOR THE A.Y. 2019-20 ISSUED BY THE RESPONDENT NO. 1 BEARING DIN VIZ ITBA/AST/F/148A/2022-23/1051439228(1) WHICH IS ENCLOSED AS ANNEXURE C AND ETC., THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:35264 WP No. 19528 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner - Assessee is before this Court seeking quashment of notices bearing No. ITBA/AST/F/148A(SCN)/2022-23/1049016984(1) dated 23.01.2023, ITBA/AST/S/148_1/2022-23/1051473594(1) dated 28.03.2023, ITBA/AST/S/156/2023-24/1062649888(1) dated 14.03.2024, ITBA/PNL/F/271AAC(1)/2024- 25/1064246752(1) dated 22.04.2024, ITBA/PNL/F/272A(1)(d)/2024-25/1064246711(1) dated 22.04.2024, ITBA/PNL/F/270A/2024-25/1064294315(1) dated 23.04.2024, ITBA/PNL/F/271A/2024-25/1064294250(1) dated 23.04.2024, ITBA/PNL/F/271B/2024-25/1064294095(1) dated 23.04.2024 and order Nos.ITBA/AST/F/148A/2022- 23/1051439228(1) dated 27.03.2023, ITBA/AST/S/147/2023- 24/1062649813(1) dated 14.03.2024 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. - 4 - HC-KAR NC: 2025:KHC:35264 WP No. 19528 of 2024 2. Heard Sri Sachin S. Nayak, learned counsel for the petitioner and Sri Y.V.Raviraj and Sri M. Dilip, learned counsel for the respondents. 3. The grounds projected in the subject petition in support of the prayer quoted supra are identical to the ones considered by this Court in W.P.No.28182/2024 and connected matters, disposed on 28.08.2025. 4. In the light of the issue being similar and the reasons rendered therein becomes applicable to the case at hand, the petition deserves to be disposed on the same lines. Therefore, I pass the following: ORDER (i) The impugned notices bearing No. ITBA/AST/F/148A(SCN)/2022-23/1049016984(1) dated 23.01.2023, ITBA/AST/S/148_1/2022- 23/1051473594(1) dated 28.03.2023, ITBA/AST/S/156/2023-24/1062649888(1) dated 14.03.2024, ITBA/PNL/F/271AAC(1)/2024- 25/1064246752(1) dated 22.04.2024, ITBA/PNL/F/272A(1)(d)/2024-25/1064246711(1) dated 22.04.2024, ITBA/PNL/F/270A/2024- 25/1064294315(1) dated 23.04.2024, - 5 - HC-KAR NC: 2025:KHC:35264 WP No. 19528 of 2024 ITBA/PNL/F/271A/2024-25/1064294250(1) dated 23.04.2024, ITBA/PNL/F/271B/2024- 25/1064294095(1) dated 23.04.2024 issued by the jurisdictional Assessing Officer outside the scope of Section 151A of the Act stand obliterated. All further proceedings initiated thereto, challenged in this petition would stand quashed. (ii) Liberty is reserved to the respondents - revenue to revive the petition in the event, the Apex Court would hold in favour of the Revenue in the matter pending before it. (iii) With the aforesaid liberty and to the aforesaid extent, the petition is allowed. (iv) Contentions of both the parties except the one noted hereinabove, shall remain open to be considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE NVJ List No.: 1 Sl No.: 386 CT.sm